California, United States of America
The following excerpt is from Han v. City of Pomona, 37 Cal.App.4th 552, 43 Cal.Rptr.2d 616 (Cal. App. 1995):
4 The only excuse given for this lengthy delay is that plaintiff's attorney lost contact with plaintiff. This excuse for delay was rejected in Garcia v. City etc. of San Francisco (1967) 250 Cal.App.2d 767, 771, 58 Cal.Rptr. 760, the court finding that it would not constitute excusable neglect for failure to file a timely tort claim.
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